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Home My WebLink About20081117IPC 41-48 to Staff.pdfLISA D. NORDSTROM Senior Counsel HIDA~PO~ An IDACORP Company November 14,2008 VIA HAND DELIVERY Jean D. Jewell, Secretary Idaho Public Utilities Commission 472 West Washington Street P.O. Box 83720 Boise, Idaho 83720-0074 Re: Case No. IPC-E-08-10 General Rate Case Dear Ms. Jewell: Enclosed for filing please find an original and three (3) copies of Idaho Power Company's Third Production Request to the Commission Staff. Upon receipt of this filing, I would appreciate it if you would return a stamped copy of this letter for my file in the enclosed stamped, self-addressed envelope. Very truly yours, ~:A- £Jr7o~ Lisa D. Nordstro~ LDN:csb Enclosures P.O. Box 70 (83707) 1221 W. Idaho St. Boise, ID 83702 BARTON L. KLINE, ISB #1526 LISA D. NORDSTROM, ISB #5733 DONOVAN E. WALKER, ISB #5921 Idaho Power Company P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-2682 Facsimile: (208) 388-6936 bklineCCidahopower.com InordstromCCidahopower.com dwalkerCCidahopower.com RECEIVED Z008 NOV 14 PH 4: 43 IDAHO PUBLIC UTllIT!ES COr.1M1SSION Attorneys for Idaho Power Company Street Address for Express Mail: 1221 West Idaho Street Boise, Idaho 83702 BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MAnER OF THE APPLICATION OF IDAHO POWER COMPANY FOR AUTHORITY TO INCREASE ITS RATES AND CHARGES FOR ELECTRIC SERVICE. ) ) CASE NO. IPC-E-08-10 ) ) ) ) ) IDAHO POWER COMPANY'S THIRD PRODUCTION REQUEST TO THE COMMISSION STAFF COMES NOW, Idaho Power Company ("Idaho Power" or "the Company"), by and through its attorneys, and hereby requests that the Idaho Public Utilities Commission Staff ("Staff") answer the following production requests and provide the following information and documents in accordance with the Commission's Rules of Procedure and applicable scheduling orders and notices issued by the Commission in this proceeding. IDAHO POWER COMPANY'S THIRD PRODUCTION REQUEST TO THE COMMISSION STAFF - 1 To allow the Company to utilize these responses in preparing its rebuttal testimony, it is necessary that the responses to these production requests be provided as soon as possible, but no later than November 24, 2008. This production request is to be deemed continuing in nature and Staff is requested to provide, through supplementation, additional documents or information that is responsive to this request that it, or any person acting on its behalf, may later come into possession or become aware of. REQUEST NO. 41 TO STAFF WITNESS VAUGHN: Please provide the detailed calculation and any workpapers and/or supporting documentation to explain the adjustments to Sales Revenues included in Staff witness C. Vaughn's Exhibit No. 126, line 17. REQUEST NO. 42 TO STAFF WITNESS VAUGHN: Please describe generally how Commission employees pay for and are reimbursed for expenses incurred while traveling and/or performing PUC business. Specifically, (a) Do Commission employees have access to credit cards where expenses are charged directly to the State of Idaho? (b) How are reimbursement requests reviewed and approved? (c) Can PUC employees obtain cash advances for travel expenses? REQUEST NO. 43 TO STAFF WITNESS VAUGHN: In her testimony on page 22, lines 3-4, Staff witness C. Vaughn states that "a line-by-line examination of all expenditures was performed by Commission Staff." Please clarify whether this examination was for the 75 randomly selected monthly P-Card reconciliations or for all P-Card expenditures for the test period. IDAHO POWER COMPANY'S THIRD PRODUCTION REQUEST TO THE COMMISSION STAFF - 2 REQUEST NO. 44 TO STAFF WITNESS VAUGHN: In her testimony on page 26, lines 23-25, Staff witness C. VaUghn states "I moved 50% of all expenditures classified as "Restaurant" below the line to eliminate expenditures that are believed to be excessive." As an addendum to Idaho Power Request No. 36, please provide Staff witness C. Vaughn's calculation of the error rate used for the extrapolation for the disallowance of 50% of the expenditures. REQUEST NO. 45 TO STAFF WITNESS VAUGHN: Please provide all supporting documentation and analysis Staff witness C. Vaughn relies on to support her conclusion that the identified P-card expenses of $884,747, included Exhibit 125, pages 1 and 2, should be moved below the line for ratemaking purposes. REQUEST NO. 46 TO STAFF WITNESS VAUGHN: Of the identified P-Card expenses included in Staff witness C. Vaughn's Exhibit 125, pages 1 and 2, did Staff pull and audit the individual P-Card envelope that supported those charges and review them to support Staffs conclusion that they should be excluded from recovery in rates? REQUEST NO. 47 TO STAFF WITNESS VAUGHN: Please provide a complete listing including, but not limited to the date of transaction, dollar amount, description of purpose and individual's name for the P-Card envelopes that were pulled and reviewed that have charges included in Staff witness C. Vaughn's Exhibit 125, pages 1 and 2. REQUEST NO. 48 TO STAFF WITNESS LANSPERY: On page 5 of Staff witness B. Lanspery's Direct Testimony, he states "Effective TOU rates. . . can result in higher overall consumption with lower bils if enough energy is shifted off-peak." Please provide studies, analyses, and/or references that substantiate this statement. IDAHO POWER COMPANY'S THIRD PRODUCTION REQUEST TO THE COMMISSION STAFF - 3 DATED at Boise, Idaho, this 14th day of November 2008. ~Q.~~LiRDSTRõM Attorney for Idaho Power Company BARTON L. KLINE Attorney for Idaho Power Company DONOVAN E. WALKER Attorney for Idaho Power Company IDAHO POWER COMPANY'S THIRD PRODUCTION REQUEST TO THE COMMISSION STAFF - 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 14th day of November 2008 I served a true and correct copy of IDAHO POWER COMPANY'S THIRD PRODUCTION REQUEST TO THE COMMISSION STAFF upon the following named parties by the method indicated below, and addressed to the following: Commission Staff Weldon B. Stutzman Deputy Attorney General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Neil Price Deputy Attorney General Idaho Public Utilities Commission 472 West Washington P.O. Box 83720 Boise, Idaho 83720-0074 Industrial Customers of Idaho Power Peter J. Richardson, Esq. RICHARDSON & O'LEARY PLLC 515 North 2ih Street P.O. Box 7218 Boise, Idaho 83702 Dr. Don Reading Ben Johnson Associates 6070 Hill Road Boise, Idaho 83703 Idaho Irrigation Pumpers Association, Inc. Randall C. Budge Eric L. Olsen RACINE, OLSON, NYE, BUDGE & BAILEY, CHARTERED P.O. Box 1391 201 East Center Pocatello, Idaho 83204-1391 -- Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Weldon.stutzmanCCpuc.idaho.gov -- Hand Delivered U.S. Mail _ Overnight Mail FAX -- Email Neil.priæCCpuc.idaho.gov Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email peterCCrichardsonandoleary.com Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email dreadingCCmindspring.com Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email rcbCCracinelaw.net eloCCracinelaw. net IDAHO POWER COMPANY'S THIRD PRODUCTION REQUEST TO THE COMMISSION STAFF - 5 Anthony Yankel Yankel & Associates, Inc. 29814 Lake Road Bay Vilage, Ohio 44140 Kroger Co. I Fred Meyer and Smiths Michael L. Kurt Kurt J. Boehm BOEHM, KURTZ & LOWRY 36 East Seventh Street, Suite 1510 Cincinnati, Ohio 45202 The Kroger Co. Attn: Corporate Energy Manager (G09) 1014 Vine Street Cincinnati, Ohio 45202 Kevin Higgins Energy Strategies, LLC Parkside Towers 215 South State Street, Suite 200 Salt Lake City, Utah 84111 Micron Technology Conley Ward Michael C. Creamer GIVENS PURSLEY, LLP 601 West Bannock Street P.O. Box 2720 Boise, Idaho 83701-2720 Dennis E. Peseau, Ph.D. Utility Resources, Inc. 1500 Libert Street SE, Suite 250 Salem, Oregon 97302 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email tonyCCyankel.net Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email mkurtCCBKLlawfirm.com kboehmCCBKLlawfirm .com Hand Delivered -- U.S. Mail _ Overnight Mail FAX Email Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email khigginsCCenergystrat.com Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email cewCCgivenspursley.com mccCCgivenspursley.com Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email dennvtempCCyahoo.com IDAHO POWER COMPANY'S THIRD PRODUCTION REQUEST TO THE COMMISSION STAFF - 6 Department of Energy Lot R. Cooke Arthur Perry Bruder Offce of the General Counsel United States Department of Energy 1000 Independence Avenue SW Washington, DC 20585 Routing Symbol GC-76 Dwight D. Etheridge Exeter Associates, Inc. 5565 Sterrett Plaæ, Suite 310 Columbia, MD 21044 Hand Delivered U.S. Mail -- Overnight Mail FAX -- Email Lot.CookeCChg.doe.gov Arthur. BruderCChg .doe.gov Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email detheridge(âexeterassociates.com Community Action Partnership Association Of Idaho Brad M. Purdy Attorney at Law 2019 North 17th Street Boise, Idaho 83702 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email bmpurdyCChotmail.com Snake River Allance Ken Miler Snake River Allance P.O. Box 1731 Boise, Idaho 83701 Hand Delivered -- U.S. Mail _ Overnight Mail FAX -- Email kmilerCCsnakeriverallance.org ot12~Lisa D. Nordst m IDAHO POWER COMPANY'S THIRD PRODUCTION REQUEST TO THE COMMISSION STAFF - 7